Last Updated: December 2024 | Version 1.0
1. Introduction
This Data Retention Policy explains how long PYROCOMPLY retains your data and the reasons for these retention periods. We retain data in accordance with:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Building Safety Act 2022
- Regulatory Reform (Fire Safety) Order 2005
- PAS 79: Fire Risk Assessment Guidance
2. Data Retention Schedule
| Data Type | Retention Period | Legal Basis |
|---|
| Fire Risk Assessments | 10 years after superseded | Building Safety Act 2022 |
| Inspection Reports | 10 years | FSO 2005 / BS 9999 |
| Compliance Certificates | Lifetime of building + 10 years | Golden Thread requirement |
| Incident Reports | 10 years | Legal / Insurance |
| Fire Drill Records | 7 years | FSO 2005 |
| Asset Maintenance Records | 7 years after asset disposal | BS 5839 / BS 5266 |
| Building Information | Lifetime + 10 years | Building Safety Act 2022 |
| User Account Data | Duration + 7 years | HMRC / Legal |
| Audit Logs | 7 years | UK GDPR / Compliance |
| Payment Records | 7 years | HMRC Requirements |
| Voice Recordings | As per parent inspection | Linked to inspection |
| Photographs | As per parent inspection | Linked to inspection |
| Marketing Preferences | Until withdrawal | Consent-based |
3. Golden Thread Requirements
Under the Building Safety Act 2022, certain buildings require a "Golden Thread" of building safety information that must be maintained throughout the building's lifecycle. This includes:
- Design and construction information
- Fire safety systems documentation
- Inspection and maintenance records
- Changes to the building
- Compliance certificates
Important: Golden Thread data for higher-risk buildings must be retained for the lifetime of the building plus 10 years. This data cannot be deleted upon request under UK GDPR Article 17 exemptions.
4. Data Deletion Procedures
4.1 Automatic Deletion
Data that has exceeded its retention period is automatically flagged for review and, where appropriate, securely deleted or anonymised.
4.2 User Requested Deletion
Users may request deletion of their personal data. We will comply unless:
- The data is required for legal compliance (e.g., fire safety records)
- The data is subject to ongoing legal proceedings
- The data forms part of Golden Thread documentation
- Retention is required for public safety reasons
4.3 Account Closure
When you close your account:
- Personal identifiable information is deleted within 30 days
- Compliance records are retained as per regulatory requirements
- You have 30 days to export your data before deletion
- Audit logs are anonymised but retained for compliance
5. Data Archiving
After the active retention period, data may be archived rather than deleted:
- Archived data is stored in secure, encrypted cold storage
- Access to archived data is restricted to authorised personnel
- Archived data is used only for legal/compliance purposes
- Regular audits ensure archive integrity
6. Legal Holds
Data may be retained beyond normal retention periods when:
- Subject to litigation or legal proceedings
- Required for regulatory investigation
- Part of an enforcement action
- Required by court order
7. Data Portability
You can export your data at any time in the following formats:
- PDF: For inspection reports and certificates
- Excel: For asset and inspection data
- JSON: For technical data integration
- CSV: For bulk data export
Contact support@pyrocomply.com for bulk export requests.
8. Third-Party Data Processors
Our data processors are contractually required to:
- Process data only on our instructions
- Delete or return data upon termination
- Maintain equivalent security standards
- Assist with data subject requests
9. Security During Retention
All retained data is protected by:
- Encryption at rest (AES-256)
- Encryption in transit (TLS 1.3)
- Role-based access controls
- Regular security audits
- Intrusion detection systems
- Backup redundancy
10. Review and Updates
This policy is reviewed annually or when:
- Legislation changes
- New regulatory guidance is issued
- Our services change significantly
- Industry best practices evolve
11. Contact
For questions about data retention or to request data deletion:
Data Protection Officer
Email: dpo@pyrocomply.co.uk
Subject: Data Retention Query
12. Regulatory References
- UK GDPR Article 5(1)(e) - Storage Limitation
- UK GDPR Article 17 - Right to Erasure
- Building Safety Act 2022 - Golden Thread Requirements
- Regulatory Reform (Fire Safety) Order 2005
- PAS 79:2020 - Fire Risk Assessment
- PAS 8903:2023 - Golden Thread Standard
- BS 9999:2017 - Fire Safety in Buildings